Introduction

The Construction (Design and Management) Regulations 2015 (CDM 2015) affect everyone involved in construction work—including subcontractors. Yet many subcontractors remain unclear about their specific duties and how to fulfil them.

This guide cuts through the complexity to explain exactly what CDM 2015 means for subcontractors, what you must do to comply, and how to avoid the costly mistakes that catch many contractors out.

What is CDM 2015?

CDM 2015 is the primary legislation governing health and safety management in UK construction. It replaced CDM 2007 and applies to all construction projects, regardless of size or duration.

The regulations establish duties for various "duty holders"—clients, principal designers, principal contractors, designers, contractors, and workers. As a subcontractor, you fall under the "contractor" category and have specific legal obligations.

Your Duties as a Contractor Under CDM 2015

Regulation 15 of CDM 2015 sets out contractor duties. Here's what you must do:

1. Plan, Manage and Monitor Your Work

You must plan your work to ensure it's carried out without risks to health and safety. This includes:

• Preparing risk assessments and method statements before starting work
• Ensuring adequate resources (time, equipment, personnel) are available
• Monitoring work as it progresses to ensure safety standards are maintained
• Taking corrective action when problems are identified

2. Ensure Workers Have the Right Skills, Knowledge and Training

Every worker you employ or engage must be competent to carry out their tasks safely. You must:

• Verify qualifications and certifications (CSCS cards, trade qualifications)
• Provide task-specific training where needed
• Ensure workers understand the hazards they'll face
• Maintain training records

3. Provide Appropriate Supervision

The level of supervision must match the risks involved and the experience of workers. Higher-risk tasks and less experienced workers need closer supervision.

4. Provide Information and Instructions

Workers must receive clear information about:

• The hazards they may encounter
• Control measures in place
• Safe systems of work
• Emergency procedures
• Site rules and requirements

5. Comply with the Principal Contractor's Directions

On projects with multiple contractors, you must follow reasonable directions from the principal contractor regarding health and safety.

6. Comply with Site Rules

You must follow the site rules established by the principal contractor, including:

• Site induction requirements
• Permit to work systems
• PPE requirements
• Working hours and access restrictions
• Reporting procedures

Documentation Requirements

While CDM 2015 doesn't specifically mandate RAMS, you'll need documentation to demonstrate compliance:

Risk Assessments

Required under the Management of Health and Safety at Work Regulations 1999, risk assessments must:

• Be suitable and sufficient for your activities
• Identify significant hazards
• Specify control measures
• Be reviewed and updated when circumstances change

Method Statements

While not legally required in all cases, method statements are expected by most principal contractors and demonstrate how you'll carry out work safely.

COSHH Assessments

If you use hazardous substances, you need COSHH assessments covering:

• What substances you use and their hazards
• Who might be exposed
• Control measures in place
• Health surveillance requirements

Common Compliance Failures

HSE inspectors regularly find these issues with subcontractors:

Generic RAMS

Using the same risk assessment for every job without adapting it to site-specific conditions. Your documentation must reflect actual conditions on each site.

Inadequate Supervision

Leaving workers unsupervised when the task or their experience level requires oversight. This is particularly common with working at height and excavation work.

Poor Communication

Failing to brief workers on site-specific hazards or changes to the work plan. Toolbox talks and daily briefings are essential.

Training Gaps

Not verifying that workers hold appropriate certifications, or failing to provide task-specific training for specialist activities.

Ignoring Principal Contractor Requirements

Treating principal contractor requests as optional rather than understanding they often have regulatory backing.

Working with Principal Contractors

Your relationship with the principal contractor is crucial for CDM compliance:

Before Starting Work

• Submit your RAMS for approval before arriving on site
• Attend site induction
• Understand the construction phase plan
• Clarify interfaces with other trades
• Agree communication protocols

During Work

• Attend coordination meetings as required
• Report hazards and near-misses promptly
• Obtain permits before starting controlled activities
• Notify of changes to your work methods
• Cooperate with other contractors

On Completion

• Provide as-built information if required
• Contribute to the health and safety file
• Complete handover documentation
• Leave the work area safe for following trades

Enforcement and Penalties

The HSE actively enforces CDM 2015. Penalties for non-compliance include:

• Improvement notices: Requiring you to remedy a breach within a specified time
• Prohibition notices: Stopping work immediately where there's risk of serious injury
• Prosecution: Leading to unlimited fines and potential imprisonment
• Fee for intervention: You pay HSE's costs when found in material breach

Beyond HSE enforcement, non-compliance can result in:

• Removal from site by the principal contractor
• Contract termination
• Exclusion from tender lists
• Increased insurance premiums
• Reputational damage

Practical Compliance Checklist

Use this checklist to verify your CDM compliance:

• Do you have site-specific risk assessments for all activities?
• Are method statements prepared and communicated to workers?
• Can you evidence worker competence (training records, certifications)?
• Is supervision adequate for the risks and worker experience?
• Have all workers completed site induction?
• Are you following the principal contractor's site rules?
• Do you have COSHH assessments for hazardous substances?
• Are you reporting accidents and near-misses?
• Do you attend coordination meetings?
• Is your work area maintained safely?

How DocGen Can Help

Creating compliant documentation doesn't have to be time-consuming. DocGen's AI-powered platform helps subcontractors:

• Generate site-specific RAMS from video walkthroughs
• Ensure comprehensive hazard coverage
• Produce professional documentation that satisfies principal contractors
• Update documents quickly when conditions change
• Maintain consistency across multiple projects

Conclusion

CDM 2015 compliance isn't optional—it's a legal requirement that protects your workers, your business, and your reputation. By understanding your duties and implementing systematic processes, you can ensure compliance without it becoming a burden.

The key is treating safety documentation as a genuine tool for protecting workers, not just a box-ticking exercise. When you approach it this way, compliance becomes a natural part of how you operate.

This guide provides general information about CDM 2015. For specific legal advice, consult a qualified health and safety professional.